Ethical Responsibilities

The Company has policies regarding equal employment opportunity, all forms of workplace harassment including sexual and hostile environment harassment, non-retaliation and the reporting by employees of improper, unethical or illegal conduct or activity. Additional information about these policies can be found in our Statement of Core Values, Code of Conduct, Equal Employment Opportunity /Affirmative Action Policy, Unlawful Harassment and various other Company policies. Many of these policies are posted throughout our facilities or are available for review in Human Resources.

HR-034

Ethics Hotline

The Company recognizes that problems, misunderstandings and frustrations may arise in the workplace. It is the intent of the Company to be responsive to our employees and their concerns. Therefore an employee who is confronted with a problem or concern may use the procedures described in this policy to resolve or clarify his or her concern. The Ethics Hotline Policy and the Ethics Hotline are administered by the Chief Administrative Officer (CAO), who reports directly to the President and Chief Executive Officer (CEO).

The Ethics Hotline was created to provide a way for employees to leave anonymous and confidential (if desired) reports of concerns or complaints regarding unjust treatment, any violation of a Company policy or any suspected improper, unethical or illegal conduct or activities. Access to the Ethics Hotline is limited to the Chief Administrative Officer and the President and Chief Executive Officer.

HR-026

Statement of Core Values

Bollinger’s commitment to integrity begins with complying with all laws, rules and regulations where we do business. Further, each of us must have an understanding of the Company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Bollinger policy, we should seek the advice of the Chief Administrative Officer or Executive Management.

We are responsible for preventing violations of law and for speaking up if we see possible violations. To this end, Bollinger’s Code of Conduct outlines the Company’s compliance policies.

HR-027

Employee Code of Conduct – Government Contracts

Bollinger requires all employees to act with integrity and good judgment and recognize that accepting personal gifts, gratuities, loans or excessive entertainment from suppliers may cause legitimate concerns about favoritism.

All Bollinger employees must completely abide by the laws and regulations of local, national and international governing bodies. Adherence to high ethical standards is also expected and required. Any employee not complying with this policy shall be subject to appropriate corrective action.

If a Bollinger officer, manager or employee has any questions regarding the propriety of a gift, the disclosure of the gift must be made to their General Manager or Operations Support Manager for determination of the proper course of action. Overall, management must assure conformity to this policy by insisting on full compliance by all officers, managers, and employees.

HR-015

Gifts and Gratuities

Bollinger’s commitment to integrity begins with complying with all laws, rules and regulations where we do business. Further, each of us must have an understanding of the Company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Bollinger policy, we should seek the advice of the Chief Administrative Officer or Executive Management.

We are responsible for preventing violations of law and for speaking up if we see possible violations. To this end, Bollinger’s Code of Conduct outlines the Company’s compliance policies.

Conflicts of Interest

Bollinger prohibits its employees from engaging in any activity, practice, outside employment or acts which conflicts with the interests of the company, subsidiaries of Bollinger, or its clients.

Equal Employment Opportunity & Affirmative Action